Case Summary (G.R. No. 63996)
Background of the Cases
The issues in this litigation stem from two previous judgments: the Court of First Instance of Bulacan declared that Ramos was entitled to the right of way through Francisco's land in Civil Case No. 66-V-73, and this decision was affirmed by the Intermediate Appellate Court in CA-G.R. No. 60968-R on September 7, 1982. Francisco contends that both lower courts erred in their conclusions.
Subdivision of Property and Issuance of Right of Way
Ramos's Lot 860-A was originally part of Lot 860 owned by Cornelia and Frisca Dila. The co-owners executed a deed on December 3, 1947, resulting in the subdivision of Lot 860 into parts, including Lot 860-A, Lot 860-B, Lot 860-C, and Lot 860-D, severing the access to the public road from Lots 860-A and 860-C. After acquiring Lot 860-A in 1971, Ramos sought an easement through Francisco’s Lot 266 due to the isolation caused by prior fragments of Lot 860.
Events Leading to the Dispute
In March 1972, Ramos requested a right of way from Francisco, but negotiations failed. While Ramos managed to create a passageway through Lot 860-B owned by Epifania Dila in 1972, he later blocked this access with a concrete wall. Francisco's construction of a stone wall led to Ramos filing a suit and obtaining a writ for preliminary mandatory injunction to open the easement.
Court Proceedings and Findings
The initial court decision, which provided Ramos with a right of way, was appealed by Francisco. The trial court appointed a commissioner to inspect the disputed properties. The Court of Appeals affirmed the trial court's ruling on September 7, 1982, leading Francisco to further escalate the matter to the Supreme Court.
Legal Contentions of the Petitioner
Francisco raised several arguments before the Supreme Court: (1) Ramos had not properly alleged prior demand for the easement under Article 649 of the Civil Code; (2) the lack of public roadway access was not due to Francisco’s actions; (3) courts lack power to enforce judicial easements; and (4) Ramos was not entitled to a mandatory injunction.
Court's Analysis of Legal Requisites
The Supreme Court reiterated that a compulsory easement requires the fulfillment of four requisites outlined in Articles 649 and 650 of the Civil Code. Importantly, the Court noted Ramos had already been granted access to the road through Lot 860-B but subsequently blocked that access, thereby failing to meet the requirement that the isolation was not a result of the
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Case Background
- This case revolves around the entitlement of Cresencio J. Ramos to an easement of right of way through the property of Eusebio Francisco, specifically Lot 266 of the Malinta Estate.
- The Court of First Instance of Bulacan ruled in favor of Ramos, granting him the right of way, which was subsequently affirmed by the Intermediate Appellate Court.
- Francisco disputes the decisions of both courts, seeking a reversal.
Facts of the Case
- Lot 860, previously owned by Cornelia and Frisca Dila, was subdivided into separate lots following a deed executed on December 3, 1947.
- Lot 860-A (2,204 sq. m.) was sold to the Eugenio Sisters, who later sold it to Ramos in 1971.
- Following the sale, Ramos requested a right of way through Francisco's Lot 266, leading to failed negotiations.
- In March 1972, Ramos was granted a three-meter wide passageway through Lot 860-B owned by Epifania Dila.
- In August 1973, Ramos constructed a wall on his lot, obstructing the established right of way.
Legal Proceedings
- Ramos filed Civil Case No. 66-V-73, seeking a mandatory injunction to remove Francisco's stone wall that blocked access to his property.
- The trial court initially issued a writ of preliminary mandatory injunction in favor of Ramos, allowing him temporary access to his property.
- Francisco contended that the injunction was issued wi